Privacy notice

01 Aug 2018, 05:32pm

What this privacy notice covers

At Amnesty International UK, we believe that you have a right to privacy and we take defending that right very seriously.

We have made improvements to our privacy notice so that it is clear and easy for you to exercise the rights you are granted under data protection legislation, and for you to choose how you want to hear from us.

The purpose of this notice is to give you a clear explanation about how Amnesty International UK - and any third parties we work with - collect and use the personal information you provide to us.

We take care to ensure that we use your information in accordance with all applicable laws concerning the protection of personal information. This privacy notice explains:

If you have any questions regarding this privacy notice, please contact our Data Protection Team at Amnesty International UK, The Human Rights Action Centre, 17-25 New Inn Yard, London, EC2A 3EA, or email: dataprotection@amnesty.org.uk

Who we are

Amnesty International is a global movement of over seven million people who stand up for humanity and human rights. Amnesty International UK is part of the worldwide Amnesty movement, and is used as a collective name for:

Within the context of this privacy notice, ‘we’, ‘our’ or “Amnesty International UK” is a collective name for the Limited Company and the Trust. Both of these organisations are data controllers of your information under data protection legislation and this privacy notice applies to the Limited Company and the Trust.

This means that the two parts of Amnesty International UK act jointly to decide the purpose and manner of any data processing, and they share a pool of personal information that they process independently of each other. They do this with full transparency of the supporter information that they hold and manage.

Our dedicated Data Protection Team oversee the use of data and personal information across both parts of Amnesty International UK and are responsible for responding to enquiries you may have about your data protection rights.

What information we may collect about you

We collect information about the members and supporters in our movement who campaign and fundraise with us. The information we gather may include:

Personal information

Name, mailing address, email address, telephone number, date of birth, age, and gender where appropriate (e.g. when registering to run a marathon on our behalf).

Your preferences

We keep a record of what you’ve told us about how you like to be contacted (e.g. emails only) and what you’d like to receive (e.g. petitions about the death penalty).

Your interests

Sometimes we collect information about your interests, such as your involvement in Team Amnesty sporting events, so we can contact you about information that is relevant to you.

Your affliations

We may also collect and record any other relevant information you share with us about yourself, including your affiliations with community groups or your employer. For example, we may require your employer’s details to process a payroll gift.

Payment information

We may collect your bank account details when setting up a regular direct debit, a credit card or debit card number when processing payments by card, and details about your taxpayer status when claiming Gift Aid.

Record of your support

We collect and process information about your interactions with us, including:

Details about our contact with you through email, text message, post, on the phone or in person

Details about donations you make to us

Details about events that you register for, or attend

Any other support you provide to us.

Sensitive information

This is personal information that is more sensitive. This includes details about a person's race and ethnicity, sexual orientation, religious beliefs, trade union memberships, political opinions, and information about their health.

Sensitive information may be collected from you if you choose to provide it to us, such as when you volunteer with us, sign up to our networks, or attend our events. For example, if you tell us about your accessibility needs or dietary requirements, you are disclosing sensitive information.

Generally, we do not collect or keep a record of sensitive information. If we do need to gather this information (for example, to enable you to participate in an athletic event on our behalf) we only do so with your explicit consent. We have measures in place to protect your sensitive information and its confidentiality.

Under 18’s

As a global movement of people, Amnesty International UK embraces the fact that our supporters are of all ages. We are committed to safeguarding the welfare of all children and young people involved in our work.

If you are under 13, we will always ask for consent from a parent or guardian to collect information about you and to continue to contact you. We may also collect the name and contact details of your parent or guardian, where appropriate.

All Amnesty International UK events and petitions have clear rules on whether or not children and young people can take part. Where we do collect personal information from children and young people, we ensure that our privacy notices are ‘child friendly’ and written in clear and plain language.

Our legal basis for using your information

To comply with UK data protection rules, Amnesty International UK must have a legal justification for collecting and using your personal information.

The legal basis that we rely on will depend upon the circumstances in which we collect and use your personal information. In almost all cases, our processing of your personal information will fall into one of the following categories:

Where you have provided your consent to allow us to use your data in a certain way. For example:

Where the processing of your personal information is necessary to carry out the performance of a contract with you. For example:

Where the processing of your personal information is necessary for us to comply with a legal obligation. For example:

Where it is in our legitimate interests to contact you in order to raise funds and achieve our human rights objectives. In doing this, we have determined that such processing is not likely to be too intrusive, or excessively infringe on your rights and freedoms. For example:

In some circumstances, we may use a combination of consent and legitimate interests to process your personal information. For example, if you sign up to our Pocket Protest SMS network, we rely on your consent to send you petitions and requests for a donation by text message, and we rely on our legitimate interests to call you about getting more involved in our work:

Administration and management: including administration relating to volunteers and staff to comply with legal requirements, the provision of information and services, research, and the management of events.

Campaigning, fundraising and marketing: including sending direct marketing by post (and in some cases by telephone for existing supporters and Pocket Protest network members), thank you letters, analysis, targeting and segmentation to improve the efficiency of our communication and manage your communication preferences, and in some cases, advertising goods and services similar to those which you have shown interest in before. To find out more about how we process your information, or if you would like to change how we contact you, please contact us.

How we use your information

In our Supporter Promise, we have committed to making it convenient for you to tell us how you want to hear from us. We carefully manage the communications we send you to ensure we are contacting you in the most appropriate way. If you ask us to stop contacting you, we will, unless we are legally obliged to communicate with you.

We may use the personal information we collect from you to:

Provide you with information about us and the work that we do, including products and services that you’ve asked for online or from our shop.

How we will contact you

The table below explains how we will contact you about human rights issues, including direct marketing relating to our campaigns, fundraising appeals and events.

We have processes in place to review how we communicate with you, especially in situations where you have not engaged with us for a while, or where the circumstances of how you interact with us change. Where you tell us that you no longer want our updates, we will act on this as soon as we can.

We will only contact you by email if you have given us your consent along with your email address. An exception to this is where you have recently made a purchase from the Amnesty shop, as we can use the ‘soft opt-in’ grounds to contact you about similar products and services, unless you say no to emails from us.

Email is low-cost and fast to send and respond to, and time is often not on our side when we are fighting to protect the life or freedom of an individual. You can opt out at any time by clicking on the ‘unsubscribe’ link at the bottom of our emails.

We will only contact you by text if you have given us your consent along with your mobile phone number. Text messages are a fast and low-cost way to ask you to support a petition, stand up for an individual whose rights are being abused and occasionally, to raise funds. You can opt out at any time by following the unsubscribe instructions in our text messages.

From 25th May 2018, if you are new to Amnesty International UK, we will only contact you by telephone if you have given us your consent along with your phone number. Exceptions to this are:

where you have signed up to our Pocket Protest SMS network, or taken a text-based action, as we will use your mobile phone number to call you about the impact of your activism, and to ask you to make a donation to support our human rights work.

where you sign up to fundraise for us (for example, by participating in an event or organising your own), as we will call you about ways you can achieve your fundraising target and how we can support you.

If you have already provided us with your phone number, we may call you occasionally, and will be checking that you consent to future phone contact during the call. Being able to call our supporters is important to our ability to raise funds quickly, and most of our calling is carried out by Amnesty International UK staff who share your passion for protecting our human rights. You can opt-out of phone calls at any time by contacting us.

If you have provided us with your postal address, we may send you post unless you have told us that you would prefer not to receive such information. You can opt-out of receiving post from us at any time by contacting us.

Where needed, we may also contact you for administrative purposes using the contact details that you have given us - for example, in relation to Gift Aid claims or to post you a product which you have bought from us.

Profiling and research

We regularly use profiling techniques to target our resources and fundraising activity more effectively, so that we can make appropriate requests to those who have the means and the desire to give more. We do this in the following ways:

Due diligence

In order to protect the reputation of Amnesty International UK, our fundraising policy and procedures (as well as certain legal and regulatory obligations), may require us to use your personal information to carry out due diligence on your donation. We may need to use publicly available information to conduct ethical screenings on potential donors of a significant gift, to ensure our reputation is protected. This might include researching the sources of the donor’s money, previous business practices and reputation.

If you choose not to have your personal information analysed for due diligence purposes, we may not be able to accept your donation.

Using publicly available information

When communicating with individuals who have given, or might consider giving, a substantial donation to Amnesty International UK, we may seek to find out more about that individual, their interests and their motivations for giving, and may invite them to become more involved in supporting our human rights work.

We do this by collating biographical, financial, corporate and philanthropic information from a wide variety of sources, including information that is held on our supporter database and information that is publicly available. This publicly available information could be obtained by searching for current directorships listed on Companies House or relevant newspaper or media coverage about an individual.

Other sources of data that we use include:

Nexis UK - collates press mentions about individuals from a range of sources

Debrett’s – a source of biographical information about notable people

Who’s Who - a source of biographical information about influential people

Mint UK – a database that allows us to find out more about companies

192.com – a directory of information about people and businesses in the UK

Zoopla – information about house prices in an area where an individual lives

An example of how this might work in practice is illustrated below.

If you would prefer for us not to use your information in this way, please contact us.

Targeted supporter communications

We want to ensure our updates are as interesting and engaging as they can be to our supporters, so we tailor our communications based on what we know about our supporters’ interests and experiences. This also helps us with using our resources as efficiently as we can.

We do this by using profiling and analysis techniques to target our marketing communications. This involves analysing responses to our previous campaigns and fundraising appeals, to look for patterns amongst our current supporters which we can then use to tailor who we send communications to in the future. We also use commercially available information, provided to us at the postcode-level, to analyse geographic and demographic trends. This is so we can send relevant campaigns and fundraising appeals to supporters who would be the most interested in them.

Who might we share your information with

Amnesty International UK respects your right to privacy and your ability to choose how you hear from us. We do not sell your details to anyone. We do not make cold telephone calls to members of the public and we do not purchase information in order to do so.

We will, except as indicated below, only share your details with third parties if you ask us to – for example, when you sign our petitions, or where we believe we are under a legal or regulatory duty to do so – for example, in a situation where we need to safeguard a vulnerable person.

Third parties

We use external service providers to help us send you communications and provide you with our services. These providers may include payment providers, fundraising agencies, fulfilment houses, mailing houses, charitable lottery managers, mobile marketing providers and software platform providers. Where needed, we would give relevant persons within these service providers access to your personal information, but only after we have conducted the necessary checks.

Everything an external service provider does is strictly governed by a contract. In addition, before we share any information with those service providers, we put in place a signed Data Processing Agreement which confirms that the personal information we provide will only be used for the purposes we specify and will be processed in line with data protection legislation. As part of this agreement, the provider needs to comply with strict security measures, including having a secure method for disposing of personal information when it is no longer needed and having a secure process for transferring personal information - for instance, by using encryption.

Some service providers may be based outside of the European Economic Area (EEA). We ensure any data transfers outside of the EEA are compliant with relevant data protection legislation and that the processing of your personal information is protected by appropriate security measures. For example, organisations we work with who process data in the US must have verified that their data processing standards meet the EU-US Privacy Shield framework. This framework sets out clear safeguards and transparency responsibilities for US-based organisations processing the data of EU citizens.

From time to time, Amnesty International UK may work in partnership with other organisations on a fundraising activity or campaign. For example, if you sign up to run a marathon on our behalf, you may receive joint communications from Amnesty International UK and the marathon sponsor, if you have indicated that this is okay.

If you would like to learn more about how and when we share personal information with external service providers, please get in touch.

Facebook

We participate in Facebook’s Custom Audience and Lookalike Audience programs, which enable us to display our content to our existing or potential supporters on Facebook. We provide personal information such as your email address or phone number to Facebook which securely encrypts it. That personal information is then deleted by Facebook if it does not match with a Facebook account or once they confirm you have an account.

Ensuring your information is accurate

We only hold your personal information on our systems for as long as is necessary for the purposes outlined above. We remove personal data from our systems once it is no longer required, in line with our guidelines on how long important information must remain accessible for future use or reference, as well as when and how the data can be destroyed when it is no longer needed.

The length of time each category of data will be retained will vary depending on how long we need to process it for, the reason it was collected, and in line with any statutory requirements. After this point the data will either be deleted, or we may retain a secure anonymised record for research and analytical purposes.

In certain situations, for example where a supporter has told us they are going to remember Amnesty International UK with a gift in their will, we will retain their details so that we can effectively administer the gift and communicate appropriately with their next of kin or executor.

We continually strive to improve the quality and accuracy of the information you have provided, such as your contact details, by regularly checking against the following (where relevant):

External data lists

Post Office’s National Change of Address database
The National Deceased Register

Preference management services

Fundraising Preference Service
Telephone Preference Service

Your contact preferences are then recorded and updated on our secure database software. We respect your choices and will not contact you by a particular channel if your details are registered with official preference (‘opt out’) services. For example, we would not phone you if your number was registered with the Telephone Preference Service, unless you have specifically given us your consent to receive phone calls from us.

Keeping your personal information safe

Amnesty International UK has robust measures in place to ensure our physical and technical systems are secure. We take appropriate precautions to protect all personal information we keep on our database, including using encryption and monitoring access to our secure networks and systems.

We also take care to ensure we have secure systems for processing your payment information, such as your credit card or debit card details. Our current payment service providers use a range of methods to protect your personal information including secure payment gateways, fraud screening and IP address blocking.

Despite our best efforts to protect your personal information electronically, the security of information sent over the internet cannot be guaranteed and may be illegally intercepted or changed after it has been sent. Amnesty International UK cannot accept liability for this if this happens.

Other ways we look after your personal information

We report to our principal Boards (governing the Amnesty International UK Section and the Amnesty International UK Section Charitable Trust) on data protection through regular briefings, meetings and other appropriate channels where required.

Amnesty International UK also has a dedicated Data Protection Team, who oversee our compliance with data protection rules and are our main point of contact for data protection enquiries.

Our Data Protection Team are responsible for:

Training all our staff and volunteers involved in data processing

Educating the organisation on the importance of being compliant

Maintaining comprehensive records of all data processing

Providing guidance and advice to the organisation and our staff and volunteers as required

Data protection training

We provide data protection guidance and training for our staff and volunteers in our offices and bookshops so they are aware of their data protection responsibilities. Training is provided when staff and volunteers first join us, and every year after this as refresher training. Our data protection training covers UK data protection law, the risks associated with using personal information and how to handle personal information responsibly in compliance with the law.

Entering your details on the Fundraising Preference Service (FPS) website and choosing ‘Amnesty International UK’ (Charity Number 1051681).

The FPS is run by the Fundraising Regulator, and allows you to stop email, telephone, addressed post, and/or text messages from a selected charity or charities by using the online service at www.fundraisingpreference.org.uk or by calling the telephone helpline on 0300 303 3517. Once you have made a request through the FPS, we will ensure that your new preferences take effect within 28 days of your request.

We treat an opt-out through the FPS as constituting an opt-out to both parts of Amnesty International UK, including our Limited Company and charitable Trust.

Your data protection rights

You are in control of how we use your data and you have the right to ask us to stop processing your personal information. You also have the right to request a copy of the information we hold about you.

You are also granted a number of additional rights under data protection legislation, which are outlined below:

Where we are processing data based on your consent, you have the right to withdraw consent at any time. Please see ‘Managing your contact preferences’ for more information on how to do this.

You have the right to change your personal information if it is incomplete or inaccurate.

You have the right to request the deletion or removal of your personal information in certain circumstances, including where it is no longer necessary for us to hold it for the purposes for which we are processing it.

You have the right to restrict our processing of your data if there is disagreement about its accuracy or legitimate usage.

You have the right to move, copy or transfer your personal information easily and safely from one IT environment to another, in some circumstances.

You have the right to object to processing based on legitimate interests (as described above) including profiling activity, and “direct marketing”.

Please note that these rights are not exercisable in all circumstances. For example, personal data might not have to be erased if it is needed in the interests of public health, or to support legal claims, compliance and scientific or historical research.

Subject Access Requests

If you would like to request a copy of the personal information that Amnesty International UK holds on you, please contact our Data Protection Team and we will respond to your request at the latest within one month of receipt.

Making a complaint

Listening and responding to feedback from our supporters and members is very important to us.

You can make a complaint or raise a concern about how we process your personal information by contacting our Data Protection Team.

We will acknowledge a complaint about any aspect of our data protection policy within 5 working days and aim to resolve complaints within 10 working days of receiving it. If you are dissatisfied with our response, please contact us using the details below.

If you are not happy with how we have handled your complaint, you can contact the Information Commissioner’s Office (which is responsible for upholding information rights in the UK) or the Fundraising Regulator (which is responsible for overseeing fundraising activities carried out by charities and similar organisations in the UK). Alternatively, you may choose to contact these bodies directly, regardless of whether you have raised the complaint with us first.

Changes to this privacy notice

This privacy notice may change from time to time. For example, we may update this notice to reflect any relevant changes to legislation and regulation, and any changes to Amnesty International UK policy.

Please visit this website section periodically to keep up-to-date with the changes in our notice.

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